Recent Webinar Regarding Health Plan Provisions in Consolidated Appropriations Act: New Legislation Brings COVID-19 Relief and Shines a Light on Health Plan Price Transparency

As the pandemic continues, employers are increasingly faced with compliance challenges in response to new and pending legislation. Click here to view our webinar recording as members of Faegre Drinker’s benefits and executive compensation group discussed various welfare benefits provisions in the Consolidated Appropriations Act, 2021 and the new provisions employers will need to navigate. Specifically, our team explored:
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Mental Health Parity: Comparative Assessments Required for Certain Nonquantitative Treatment Limits in Group Health Plans

As noted in several recent blog posts, the year-end Consolidated Appropriations Act (CAA) included a number of employee benefits-related changes. One set of changes represents an effort to further strengthen protections under the Mental Health Parity and Addiction Equity Act (MHPAEA). These new provisions will require group health plans and health insurance issuers (collectively, “group health plans”) that provide both medical and surgical (M/S) benefits and mental health or substance use disorder (MH/SUD) benefits and that impose nonquantitative treatment limitations (NQTL) on MH/SUD benefits to perform comparative analyses to demonstrate compliance with mental health parity requirements. Plans will also be required to provide that comparative information to the DOL, HHS or applicable State authority upon request (DOL for ERISA-governed group health plans). These new requirements go into effect February 10, 2021 (45 days after enactment of the CAA).

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